Segmentation is the biggest challenge of the new transfer pricing rules

One of the most challenging aspects of the new transfer pricing decree is the tightening of expectations regarding segmentation. This is even more pronounced when fulfilling transfer pricing obligations for the 2025 tax year, which serves as a transitional period: certain elements may already follow the new rules, while others must still comply with the previous regulations.

 

Is it worth applying the new transfer pricing rules for 2025?

The new transfer pricing regulation, which will become mandatory from 2026, can already be applied to the 2025 tax year—for example, by allowing taxpayers to omit local documentation for transactions below HUF 150 million. Although this may seem beneficial at first glance, in practice it tends to increase risks.

Which form of asset management is the better choice for preserving wealth?

 The table below outlines the differences between a trust foundation and a fiduciary trust.

A trust is the solution for managing substantial assets

If you are looking for a solution to preserve your substantial assets over the long term, manage them effectively, and facilitate a tax-efficient generational transfer, a trust may be the right tool for you.

Equal Pay for Equal Work: The Principle in Practice

In interpreting and applying this principle, companies can rely not only on the Pay Transparency Directive but also on EU case law, which provides useful methodological guidance for objectively comparing the value of different job roles. However, the Hungarian implementing regulation has not yet been adopted.

Don’t leave your GloBE filing and reporting obligations due on June 30 until the last minute

The legal framework for implementing tasks related to the global minimum tax (GloBE) is continuously evolving. In recent months, several implementing regulations have been published. The autumn tax package refined the conceptual framework of the global minimum tax and the rules on information exchange. These provisions must be applied when fulfilling the obligations due on 30 June 2026, and since the rules are quite complex, preparation should not be postponed.

Reform of the EU Social Security Regulation Expected Soon

According to current plans, the proposed reform of the EU social security framework may take place in the first half of 2026, creating new challenges and opportunities in the field of cross-border employment. Changing forms of work, a mobile workforce, and digitalisation are giving rise to increasingly complex legal and administrative issues.